Michigan sets April 1st EVV enforcement

Michigan is moving from EVV rollout to enforcement. In Bulletin MMP 26-10, the Michigan Department of Health and Human Services (MDHHS) states that, effective April 1, 2026, the state “will enforce EVV compliance” for personal care services (PCS) and home health care services (HHCS) providers. The enforcement notice applies to PCS and HHCS providers across fee-for-service and managed care arrangements. MDHHS includes fiscal intermediaries (FIs) and financial management services (FMS) providers in the scope, along with MI Choice Waiver providers and other managed care entities listed by MDHHS.

MDHHS ties enforcement to the 21st Century Cures Act EVV requirement for PCS and HHCS. The bulletin also reiterates the federally mandated EVV data elements: service type, person receiving service, date, location, provider, and begin/end time. Michigan continues its open vendor model. Providers may use the state EVV system or their own EVV tool, as long as EVV data are sent to the state aggregator. The bulletin frames compliance as outcomes-based, not dependent on vendor selection.

Operationally, the bulletin highlights “manual edits” as a key compliance risk. MDHHS states an expectation of electronic reporting via mobile device or interactive voice response (IVR) and clarifies circumstances that count as manual entry or manual edit. Examples include missing clock-in or clock-out, missing caregiver, and missing GPS coordinates when using mobile apps. MDHHS also sets a quantified performance expectation. Providers should achieve a quarterly threshold of 85% of EVV records for verified visits without manual edits. The state indicates this is measured per payer, including MDHHS and each managed care entity where relevant.

The bulletin describes monitoring through HHAeXchange portals. It also outlines a progressive corrective-action ladder for persistent noncompliance. The steps listed include retraining, mandatory training, compliance plans, formal meetings, and potential further action. MDHHS also references a defined grace period concept for certain scenarios.

For IDD service providers delivering PCS-like supports through waivers and community programs, Michigan’s approach positions EVV as a day-to-day compliance KPI. The 85% “no manual edits” target can drive workflow redesign, staff training, device access, and rapid exception management. Providers with high rural coverage, unpredictable schedules, or higher use of live-in or irregular supports may be disproportionately challenged under the manual edit expectations.